The case of the day is Amazon, Inc. v. Glenn (W.D. Wash. 2018). It’s an odd case. Amazon won an arbitration award against Thomas Glenn, who resided in the Dominican Republic. It sought to confirm the award. The clerk “mailed the petition to Respondent’s address in the Dominican Republic, in accordance with the Hague Convention on the Service Abroad of Judicial and Extrajudicial Documents in Civil or Commercial Matters, Article 10(a).” Glenn defaulted, and the court entered judgment. What could be simpler?

The odd thing is that the Dominican Republic is not, according to the Hague Conference website, a party to the Hague Service Convention. That’s not to say that the service was bad. But the case should be cited with extreme caution. Perhaps it should go without saying, but the Hague Service Convention applies in American litigation only when the state in which the documents are to be served is itself a party to the Convention.